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AAan Gales
Direct Dial: 50 1-688-8816
Fax: 501-918-7816
E-mail. agatMCmwlaw.eom
MITCHELL WILLIAMS
July 29,2011
Vill Electron ic Deli ve rv & First Class Mail
Mr. Phillip Moershel
Mr. Jason Childress
Water Quality Standards Section
Oklahoma Water Resources Board
3800 N. Classen Boulevard
Oklahoma City, OK 73 11 8
425 West Capilol Avenue. Suite 1600
little Rock, Arkansas 72201-3525
Telephone: 501-666.a800
Fill!: 501-686-8807
Re: Response to OWRB Call for Submissions to Technical Advisory Group
Dear Messrs. Moershe l & Childress:
We have been retained by the Northwest Arkansas Regional Planning Commission 10
assist the Commission 's lntergovernmental Working Group wi th respect to water quality
planning issues re lated to the Illinois River. The Intergovernmental Working Group members
represenl the ci ties o f Bentonville, Fayettevi lle, Rogers, Siloam Springs, and Springdale,
Arkansas. Each of the five cities owns or is served by a wastewater treatment facili ty that
discharges into a tributary of the lIIinois River. In addition, the cit ies are s ituated such that some
port ions of the storm water run-off in the Upper Illinois River watershed originates within their
boundaries. As a consequence, the cities have a d irect interest in the decisions that will be made
by Oklahoma and EPA in the reevaluation of Oklahoma's numeric water qual ity standard for
phosphorus in the Oklahoma Scenic Rivers.
The cities recognize that the OWRB Public Notice cal led only for the subm ission of
scienti fic studies and information. The cities are aware of the sc ientific information that is being
submitted by the Wright Water Engineers and Professors Matlock, Haggard, and Sharpley. The
cities concur with this infonnation and urge the OWRB Technical Advisory Group to give all of
their findings and supporting ci tations careful consideration.
In addition to purely technical sc ientific information, the cit ies believe there are some
important pract ical, economic, and legal considerations that should be included in the
reevaluation process, including the TAG delibera tions. Fai lure to include these " non-technical"
considerations in the deliberations of the TAG would risk making the TAG's recommendation an
abstract theoretical exercise without adequate connection to practical reality. The cities offer the
follow ing observations on these "non-technical" cons iderations.
Mitchell, Williams, Selig, Gates & Woodyard , P.L.LC. I Attorneys at Law
Lierll.' Rock· Rogers· Austin I Mi tchdlWili iamsL1.w.com

AAan Gales
Direct Dial: 50 1-688-8816
Fax: 501-918-7816
E-mail. agatMCmwlaw.eom
MITCHELL WILLIAMS
July 29,2011
Vill Electron ic Deli ve rv & First Class Mail
Mr. Phillip Moershel
Mr. Jason Childress
Water Quality Standards Section
Oklahoma Water Resources Board
3800 N. Classen Boulevard
Oklahoma City, OK 73 11 8
425 West Capilol Avenue. Suite 1600
little Rock, Arkansas 72201-3525
Telephone: 501-666.a800
Fill!: 501-686-8807
Re: Response to OWRB Call for Submissions to Technical Advisory Group
Dear Messrs. Moershe l & Childress:
We have been retained by the Northwest Arkansas Regional Planning Commission 10
assist the Commission 's lntergovernmental Working Group wi th respect to water quality
planning issues re lated to the Illinois River. The Intergovernmental Working Group members
represenl the ci ties o f Bentonville, Fayettevi lle, Rogers, Siloam Springs, and Springdale,
Arkansas. Each of the five cities owns or is served by a wastewater treatment facili ty that
discharges into a tributary of the lIIinois River. In addition, the cit ies are s ituated such that some
port ions of the storm water run-off in the Upper Illinois River watershed originates within their
boundaries. As a consequence, the cities have a d irect interest in the decisions that will be made
by Oklahoma and EPA in the reevaluation of Oklahoma's numeric water qual ity standard for
phosphorus in the Oklahoma Scenic Rivers.
The cities recognize that the OWRB Public Notice cal led only for the subm ission of
scienti fic studies and information. The cities are aware of the sc ientific information that is being
submitted by the Wright Water Engineers and Professors Matlock, Haggard, and Sharpley. The
cities concur with this infonnation and urge the OWRB Technical Advisory Group to give all of
their findings and supporting ci tations careful consideration.
In addition to purely technical sc ientific information, the cit ies believe there are some
important pract ical, economic, and legal considerations that should be included in the
reevaluation process, including the TAG delibera tions. Fai lure to include these " non-technical"
considerations in the deliberations of the TAG would risk making the TAG's recommendation an
abstract theoretical exercise without adequate connection to practical reality. The cities offer the
follow ing observations on these "non-technical" cons iderations.
Mitchell, Williams, Selig, Gates & Woodyard , P.L.LC. I Attorneys at Law
Lierll.' Rock· Rogers· Austin I Mi tchdlWili iamsL1.w.com